COMES NOW the Plaintiff, The ESTATE OF LISA McPHERSON, by and through the
Personal Representative, DELL LIEBREICH, through its undersigned attorney and
sues the Defendant, CHURCH OF SCIENTOLOGY FLAG SERVICE ORGANIZATION,
INC.;BENNETTA SLAUGHTER; PRODEX, INC., a Florida corporation d/b/a/ AMC
PUBLISHING COMPANY; DAVID MINKOFF, M.D.; JANIS JOHNSON, M.D.; ALAIN KARTUZINSKI;
and DAVID HOUGHTON, D.D.S. and alleges:

GENERAL ALLEGATIONS

A. Jurisdiction

1. This is a civil action for damages which greatly exceed this court's
threshold jurisdiction of $15,000.00.

B. The Plaintiff

2. LISA McPHERSON, a single adult, was at all material times herein a
resident of Clearwater, Pinellas County, Florida, and survived solely by her
biological mother, FANNIE B. McPHERSON per Chapter 732 and Chapter 768, Florida
Statutes.

3. DELL LIEBREICH, maternal aunt of LISA McPHERSON, has been appointed the
Personal Representative of the ESTATE OF LISA McPHERSON, through consent of the
surviving heir, FANNIE B. McPHERSON, as evidenced by the Letters of
Administration dated February 4, 1997, and attached hereto as Exhibit "A."

C. The Defendants

4. The CHURCH OF SCIENTOLOGY was created in the early 1950's by science
fiction writer, L. Ron Hubbard, to avoid charges that he was practicing medicine
without a license. Hubbard was known as the originator of Dianetics, and
published in 1950 his book Dianetics: The Modern Science of Mental Health ("DMSMH").
As the title implied, Hubbard rebuked current medical science and claimed that
he had found the one and true answer to all of mankind's ailments. Dianetics was
not only an alternative to psychotherapy, it was an alternative to medicine
itself. Although Hubbard was drawing government medical disability for ulcers,
bursitis, and eye problems, Hubbard promised that his methods could cure
everything from cancer to the common cold, while producing perfect health,
perfect recall, increased abilities and happiness.

5. L. Ron Hubbard with a background in the black magic of Satanic worshiper
Aleister Crowley, hypnotism, and borrowing from Freud, Korzybski and regression
therapy, he wrote "Dianetics" in 1950. His first treatise on the
subject was in a pulp science fiction magazine. Although Hubbard used the name "Scientology,"
the word "scientology" was first coined by Dr. A. Nordenholz in his
book "Scientology: Science of the Constitution and Usefulness of Knowledge",
first published in 1934, which parallels in content to Hubbard's work. In
Scientology, all oral and written words of L. Ron Hubbard are deemed "scripture"
and cannot be altered or abandoned in any way.

6. While the book was a best-seller, the medical profession rebuked it as
quackery and possibly dangerous. When some Dianetics practitioners were arrested
for practicing medicine without a license and it appeared that Hubbard himself
might be so charged, Hubbard quickly "discovered" Scientology and the
CHURCH OF SCIENTOLOGY was formed, not only to give him a mantle of religious
protection for his anti-medical practices, but also to enable him to make more
money through a claim of tax exempt status. Hubbard began to sell weekend
courses of study and issue degrees, including a "Doctor of Scientology,"
with the additional claims about the curative powers of his methods. In the
meantime, he rebuked all criticism, saying the medical establishment knew he was
right and it was fighting to destroy him and to keep control of his empire.

7. Despite his explanations to his loyal following, the disputes and attacks
from governments increased. Hubbard was forced to leave the USA to live in the
UK. He then tried to live in what was then Rhodesia, until he was kicked out.
Threatened with being kicked out of the UK, he took to the sea and sailed the
Mediterranean, only to be kicked out of one port after another, from Greece to
Portugal. That was how the "Flag Land Base" in Clearwater was
established. "Flag" referred to the "flagship" that Hubbard
sailed. He had had a miserable Naval career, also being booted out from one
command to another. By taking to the sea, he created his own Navy and called it
the "Sea Organization" or "Sea Org," outfitting his crews in
naval uniforms and operating them in a military fashion. They were given command
of the senior organizations and told they were the "elite," and
together they could take over the world. But the seagoing "flagship"
was insecure. He needed a land base and that was how they secretly moved into
Clearwater. "Flag Land Base" was established and became known as the
CHURCH OF SCIENTOLOGY, FLAG SERVICE ORGANIZATION, INC.

8. The manner in which CHURCH OF SCIENTOLOGY FLAG SERVICE ORGANIZATION INC.
established itself on Clearwater and the manner in which SCIENTOLOGY has
conducted itself is a long pattern of conduct that demonstrates this
organization's resentment for the law, authority, the courts and the general
public. The history of deceit, deception, fraud, and illegal acts not only in
Clearwater and the USA but around the world, trace back to the mind of Hubbard
and his paranoid siege-mentality. This mentality is laid out in volumes of
directives that take many forms: bulletins, policies, orders, programmes, plans,
etc. The CHURCH OF SCIENTOLOGY has a multitude of different rules, regulations
and programs which fall under one of three captions, "Ethics," "Admn"
for administration, and "Techs" for techniques as authorized by L. Ron
Hubbard. To ensure that these were executed as he demanded, Hubbard was the
managing agent and alter-ego of the CHURCH OF SCIENTOLOGY, and all its multitude
of corporations and non-corporate entities, since he operated the CHURCH OF
SCIENTOLOGY without any formal corporate structure and answering to no one.

9. As previously judicially declared:

(a). "Scientology is both immoral and socially obnoxious... It is
corrupt, sinister and dangerous. It is corrupt because it is based on lies and
deceit, and has as its real objective money and power for Mr. Hubbard, his
wife, and those close to him at the top. It is sinister because it indulges in
infamous practices, both through its adherents who do not toe the line
unquestioningly and to those who criticize or oppose it. It is dangerous because
it is out to capture people, especially children and impressionable young
people, and indoctrinate and brainwash them so that they become the
unquestioning captives and tools of the cult, withdrawn from ordinary thought,
living and relationships with others."

(b). all 'auditing' files of Scientologists "are available to the
Scientology's Intelligence Enforcement Bureau and are used, if necessary, to
control and extort obedience of a person who is audited. If a person seeks to
escape from Scientology, his auditing files are taken by the Intelligence
Enforcement Bureau and used, if wished, to pressure him into silence."

(c). "auditing is a simple, thoroughly designed means of concentrating
the mind to a state of a controlled trance. The aim and result is progressively
to enforce loyalty to, and identification with Scientology, to the detriment of
one's natural awareness of divergent ways of thinking and outside cultural
influences."

(d). "the CHURCH OF SCIENTOLOGY is a cult engaged in ongoing criminal
activity which deprives its members of its property and freedom, and engages in
injury by any means, trickery, litigation, lying or destruction against its
critics, whose founder has also previously been judicially declared to be a
charlatan and whose Scientology techniques and bulletins remain unproven while
SCIENTOLOGISTS are ordered to and have been successful in infiltrating other
organizations and government agencies, newspapers, medical associations,
psychological associations, and psychiatric associations throughout the world
for the sole purpose of world domination.

10. "Dianetics" is not depended on faith but is completely "scientific"
according to its author, L. Ron Hubbard.

11. At all times material herein, CHURCH OF SCIENTOLOGY FLAG SERVICE
ORGANIZATION, INC., (hereinafter referred to as SCIENTOLOGY or FLAG), has been
highly promoted in Scientology literature as the "mecca," providing
the best possible services that Scientologists can purchase and they are urged
to and do come from around the world to stay at the Clearwater facility for
these purchased services. FLAG is also a management church of the collection of
unincorporated organizations and a multitude of corporations within a nominal
corporate structure that has been judicially declared to be something of a "deceptis
visus", collectively known as the CHURCH OF SCIENTOLOGY or simply
SCIENTOLOGY, where a multitude of corporations were created in order to avoid
liability for its conduct and shift assets among the corporations to further
that goal, where each nominal corporation or organization is the alter ego of
the other, comprised of similar officers and directors with disregard of
corporate structure doing business under many names where they strictly practice
Scientology in the Hubbard prescribed manner, doing business throughout the
state of Florida, with offices located in Hillsborough County and Pinellas
County, Florida, as well as throughout the world under the name "CHURCH OF
SCIENTOLOGY" or "SCIENTOLOGY" of which LISA McPHERSON was a
member.

12. After the death of L. Ron Hubbard, David Miscavige, unilaterally
appointed himself as the ultimate head of the CHURCH OF SCIENTOLOGY and
unilaterally assumed L. Ron Hubbard's position as the ecclesiastical head of all
of the CHURCH OF SCIENTOLOGY, including "Captain" or "Commander"
of the SEA ORG, self-appointed "Chairman of the Board" of RTC, "Inspector
General" of the Inspector General Network within RTC which demands
correction from standard technology, policy or ethical standards; and the "Managing
Agent" of all of Scientology having direct and supreme authority over all
operations of the entities comprising the CHURCH OF SCIENTOLOGY, and its
membership, including all responsible parties herein for the treatment and death
of LISA McPHERSON.

13. The Defendant, BENNETTA SLAUGHTER, was the employment supervisor and
supervising corporate officer of Defendant, PRODEX, INC. d/b/a AMC PUBLISHING
INC. COMPANY, which was the employer of LISA McPHERSON.

14. The Defendant, ALAIN KARTUZINSKI, was the Senior Case Supervisor and in
control over the handling of LISA McPHERSON, while the Defendants, JANIS
JOHNSON, M.D., an unlicensed medical doctor, and DAVID HOUGHTON, D.D.S., an
unlicensed dentist, are on staff or members of SEA ORG at the FLAG facility, the
FT. HARRISON HOTEL, Clearwater, Florida, and reporting to and following the
orders of KARTUZINSKI.

15. The Defendant, DAVID MINKOFF, M.D., a Florida licensed medical doctor,
is a public member of the CHURCH OF SCIENTOLOGY and a resident of Clearwater,
Florida.

16. All SCIENTOLOGY organizations operate on a week that ends on Thursday at
2 p.m. Each week, all staff and organizations write and compile what is known as
a "weekly report." These are sent up the command channels. These
command channels operate in a pyramid fashion, not unlike a military command
channel. At various echelons, the reports are re-compiled and forwarded on and
move from a local level to a regional level and then the "Int" ("international")
level. This is where Miscavige is located. Each week he receives reports from
around the world, compiled by his staff, dealing with various situations and
developments, including the amount of money brought into Scientology, court
cases and what are called "situations." A "situation" in
Scientology is usually a threat, in which officials are involved and thus some
section of the organization. LISA McPHERSON's encounter with the authorities,
before she was taken back to the Fort Harrison Hotel, (alleged hereafter), would
be that sort of situation. It would have been reported up through the command
channels, through various channels, to Miscavige.

17. SCIENTOLOGY has thousands of different directives ("directives")
that lay out the rules, regulations and procedures that govern the activities of
the organizations, the executives, the staff members and the organizations'
various customers. Most of these were written by Hubbard. These directives are
issued in different forms and different names that are unfamiliar to a
non-Scientologist. For example, HCOBs (Hubbard Communications Office Bulletins),
HCOPLs (Hubbard Communications Office Policy Letters), LRH EDs (L. Ron Hubbard
Executive Directives), GOs (Guardian Orders), FBDLs (Flag Bureau Data Letters),
PABs (Professional Auditor Bulletins), etc. These usually have a color-coding
system, for example, HCOBs are issued as red ink on white paper while HCOPLs are
green ink on white paper, etc. Distribution of these different and diverse
directives depends upon the area effected or being directed. Some directives
have the widest possible distribution while others are narrower. These
Scientology directives contain an arcane language that is so difficult for a new
Scientologist to understand that it has large dictionaries listing thousands of
words that have their own Scientology definition. These dictionaries contain
many coined or invented words, acronyms and slang terms that are part of the
Scientology language, for example, "entheta", "sec check", "OWs",
"SP", "Type III". The language extends to the structure of
the organization with areas and positions having coined or invented names that
are also in their vocabulary and/or dictionaries, for example, C/S, Tech Sec,
RPF, I&R, COB.

18. All of SCIENTOLOGY 's senior organizations and personnel are members of
the SEA ORGANIZATION (also known as the "SEA ORG" or "SO")
of which David Miscavige is the self-appointed head, as was L. Ron Hubbard.
Touted as a harmless "fraternal organization," the SEA ORG is an
unincorporated para-military organization that is the hidden nexus of
SCIENTOLOGY. It is the SEA ORG that penetrates all corporate shields but, being
unincorporated itself, and yet with its own bank accounts, internal officers and
records, it remains unseen to outsiders as the controlling force in Scientology
that allows it to be run as a totalitarian, anti-democratic movement.

19. Defendant, BENNETTA SLAUGHTER, a Scientologist, operated PRODEX, INC.
under the WISE business program, (where WISE is a Scientology business entity
promoting and enforcing Scientology business programs on businesses owned by
Scientologists), which mandates that the business be run strictly through the
implementations of the administrative methods established by L. Ron Hubbard.
These methods are laid out in various directives that were first issued to
SCIENTOLOGY and are represented by them as "religious doctrine" or "religious
scriptures." After changing the headings of these directives and a few
words to "secularize" them, they are then exported to secular
businesses through a WISE license, which is a source of income back to the
Church of Scientology which licenses WISE.

D. Material Facts concerning LISA McPHERSON

20. LISA McPHERSON joined the CHURCH OF SCIENTOLOGY at the age of 18 when
she was recruited to the CHURCH OF SCIENTOLOGY by her supervisor at work at the
Dallas, Texas telephone company.

21. While LISA McPHERSON resided in Clearwater, Florida, she was an employee
of PRODEX, INC. d/b/a AMC PUBLISHING COMPANY, a for-profit printing company.
Although PRODEX, INC. is a business, it is operated according to the
administrative policies of L. Ron Hubbard.

22. PRODEX, INC. d/b/a AMC PUBLISHING COMPANY is a member of WISE, i.e.,
World Institute of Scientology Enterprises. WISE is licensed by RTC to use
Hubbard's methods, the same methods licensed to the FLAG, including those used
on LISA McPHERSON as hereinafter alleged. PRODEX, INC. is also staffed by people
who adhere to Hubbard's policies. These methods were "secularized" to
allow SCIENTOLOGY access into areas that it cannot access as a religion, even
though they are the same methods that the CHURCH OF SCIENTOLOGY claims are "religious
scriptures," to seek First Amendment protection. These secular methods are
intended to covertly gather recruits by getting their interest in L. Ron Hubbard
without telling them that the methods are actually that of the CHURCH OF
SCIENTOLOGY, which wants to recruit them.

23. Prior to November 15, 1995, LISA McPHERSON, had experienced a "psychotic
break" , had expressed a desire to leave Scientology, was having a
difficult time at her employment as evidenced by low production in sales and
earnings, and was expressing disagreement with the rules and regulations of
SCIENTOLOGY. As a result of the above actions, LISA McPHERSON was undergoing and
died while in the middle of an "Ethics handling" to force her to
regain her momentum of sales and also to keep her from leaving the movement. The
purpose of Scientology "Ethics," as written by Hubbard, is to remove
anything that is counter or against the person doing Scientology, including the
person's own feelings, ideas, beliefs, behaviors or intentions. Thus since she
wanted to stop doing Scientology, that was counter-Scientology and so she had to
be "handled" by Hubbard's 'ethics" methodology.

24. Hubbard and Scientology advocates that there is an "ethics
technology," ("ethics tech"), a precise method to be done to a
person who is deemed to be "unethical", meaning that they are
expressing some disagreement. A primary part of this "ethics tech" is
to have a person confess to every crime or wrongdoing they have done or felt
they have done or that the organization says that they have done. These are
called "overts" and the person is required to write down their "overts"
or made to confess them in an interrogation known as a "security check"
or "sec check." These methods are part of the "tech" that is
licensed to WISE, which in turn, licenses it to SCIENTOLOGY and to AMC
PUBLISHING. People have been known to go crazy during these "ethics
handling." It was therefore extremely foreseeable to the Defendants that
given LISA McPHERSON'S prior experience of being psychotic in June of 1995,
coupled with her troubles in taking SCIENTOLOGY instruction, she would very
likely experience another psychotic episode.

25. Prior to November 15, 1995, LISA McPHERSON was undergoing this rigorous "Ethics"
program at her employer, AMC PUBLISHING COMPANY. It was being conducted by AMC
PUBLISHING COMPANY employee Katie Chamberlain, in the course and scope of her
employment. This program was known by BENNETTA SLAUGHTER and AMC PUBLISHING
COMPANY to cause LISA McPHERSON to have psychological breakdowns, and by
continuing the "ethics handling," BENNETTA SLAUGHTER and AMC
PUBLISHING COMPANY knew that she was likely to experience another "psychotic
break" which would in all likelihood result in "Isolation." On or
about November 15, 1995, LISA McPHERSON was sent to a commercial trade show in
Orlando, Florida. This was done with the knowledge of BENNETTA SLAUGHTER and AMC
PUBLISHING COMPANY that she was having difficulty with her "ethics"
program at AMC PUBLISHING COMPANY and was not mentally well. Those going to
Orlando with LISA McPHERSON were told to watch LISA because of these known
problems.

26. While in Orlando, LISA McPHERSON began to manifest unusual erratic
behavior. One night her roommate awoke at 3 a.m. to find LISA McPHERSON sitting
on top of her, sobbing hysterically about how something was wrong with the
planet and how everyone was in danger and the world had to be saved right then.
The roommate finally got LISA McPHERSON back to bed and to sleep so she could
continue to work at the convention. But the next day, LISA McPHERSON was even
worse and it was decided to take her back to Clearwater to avoid a public
relations problem for her employer, AMC PUBLISHING and Scientology.

27. LISA McPHERSON manifested what is known in Scientology "ethics tech"
as PTS Type III, ("Potential Trouble Source"). There are three types
of the "potential trouble", one of which to SCIENTOLOGY and AMC
PUBLISHING is the fear that the person might cause a legal or public relations
problem. This was known by her employer, BENNETTA SLAUGHTER and AMC PUBLISHING
COMPANY and SCIENTOLOGY, since she was exhibiting signs of a psychological
breakdown. By its own language, SCIENTOLOGY considers such people to be
potential sources of trouble and thus must deal with them.

28. Rather than assist her to obtain professional and licensed psychological
counseling, which is forbidden by SCIENTOLOGY, the members of SCIENTOLOGY placed
LISA McPHERSON in isolation against her will on November 18, 1995, at the Ft.
Harrison Hotel subjecting her to a denial of her freedom of movement, her
freedom of choice over food, her freedom to sleep and her freedom to communicate
with friends, family and professionals. Those taking care of her had strict
orders not to talk to her in any way. Thus she was incommunicado and kept in
strict isolation, a prisoner of Scientology, all according to Hubbard's
directives which the staff were following: a withholding of food and sleep,
which is according to the "tech" of SCIENTOLOGY.

29. On November 18, 1995, LISA McPHERSON, seeking to escape from this
isolation, drove her motor vehicle and lightly rear-ended a vehicle stopped in
traffic. LISA McPHERSON sustained no injuries. However, upon exiting her motor
vehicle, she requested help by stating to emergency personnel, "I NEED
HELP," I NEED TO TALK TO SOMEONE," "I HAVE DONE BAD THINGS,
THINGS I DID NOT KNOW WERE EVEN BAD," I DON'T NEED A BODY TO LIVE", in
a robotic/programmed tone with a fixed stare while exhibiting unusual behavior
by taking off her clothes in public but telling the paramedics that she was not
crazy, she was just trying to get their attention because she needed help.

30. On that date, LISA McPHERSON was then transferred by ambulance to the
Morton Plant Hospital located in Clearwater, Florida, where she sought and
received emergency medical and psychological evaluation.

31. Shortly after LISA McPHERSON arrived at Morton Plant Hospital,
SCIENTOLOGY members discovered her location and proceeded to Morton Plant
Hospital to retrieve her because she was a "potential trouble source"
by seeking help from non-Scientology resources.

32. Members of SCIENTOLOGY appeared at Morton Plant Hospital on November 18,
1995 and as a result of their continued control over her, coerced LISA McPHERSON
to reassure the medical staff that she wanted to leave with the Scientologists
and return to SCIENTOLOGY headquarters, despite her escape attempt.

33. By being in an automobile accident, acting erratic and going to an
outside source, known as a "wog," a non-member of SCIENTOLOGY, i.e.,
the paramedics and Morton Plant Hospital, LISA McPHERSON had become 'PTS' or a
'Potential Trouble Source.' Because of her psychotic behavior, she was deemed a
'PTS Type III' which, according to Scientology directives, is a person to be
found "mostly in "psychiatric institutions" because they have "ghosts
about him or demons" and other "imaginary" entities. The
Scientology "handling" for a PTS Type III is called the "Instrospection
Rundown", which requires that the person be put into isolation with "no
treatment of a mental nature at all," but with more than ample
administration of ill-conceived concoctions often laced with illegally
prescribed and administered drugs.

34. After repeated assurances by the members of SCIENTOLOGY that they would
provide 24-hour care to LISA McPHERSON, Morton Plant Hospital reluctantly and
against their own medical advice released LISA McPHERSON from Morton Plant
Hospital, placing LISA McPHERSON in the exclusive care, custody and control of
SCIENTOLOGY.

35. Immediately after leaving Morton Plant Hospital, members of SCIENTOLOGY
transported LISA McPHERSON to the Ft. Harrison Hotel, the "spiritual
headquarters" of SCIENTOLOGY in Clearwater, Pinellas County, Florida.

36. At the said headquarter facilities, SCIENTOLOGY agents, staff,
volunteers, representatives, employees, and/or other members, trained in the
methods of L. Ron Hubbard, and under the strict authority of the "Senior
Case Supervisor", ALAIN KARTUZINSKI, systematically began a series of
techniques or bulletins in following its own policies of SCIENTOLOGY which
included "isolation" as a prerequisite to, or part of, a technique or
bulletin known as "Introspection Rundown," which involves the total
isolation of LISA McPHERSON in a room against her will, where no one is to talk
to her during her isolation. During this time she was denied freedom of
movement, proper medical treatment, and she was denied proper nutrition, starved
and underwent severe dehydration including over-medication of illegally
prescribed drugs plus high dosages of vitamins and minerals, at the hands of
individuals who were trained in Hubbard's anti-medical techniques, as issued in
his directives.

37. During this time, LISA McPHERSON tried to flee and was physically
restrained, including being tied to the bed, and her condition worsened until
she was babbling incoherently and unable to sleep. No medically licensed
personnel were brought in to see her. The only qualifications of those told to
watch her was that they were available to do it. Some who saw her in her
condition could not even tolerate watching her going crazy or looking at her
morbid condition and had to leave the room.

38. The "Introspection Rundown," even according to L. Ron Hubbard,
must be followed strictly and by Scientology-trained personnel, as defined by
SCIENTOLOGY, otherwise it can be extremely dangerous and to those who wish to
abuse the Introspection Rundown, according to L. Ron Hubbard, can be used to
murder that person or cause a person to go completely and utterly insane or to
commit suicide.

39. During her confinement under the strict authority of ALAIN KARTUZINSKI
and watched over by JANIS JOHNSON and DAVID HOUGHTON, LISA McPHERSON was denied
appropriate fluids, nutrition and medical care and administered illegally
obtained prescription drugs by unlicensed persons. She became confused,
disoriented, unable to walk and care for herself, and more mentally unstable.
She ultimately slipped into a coma or coma-like state.

40. The care givers of SCIENTOLOGY permitted LISA McPHERSON to remain
malnourished and later in a coma or similar condition for an extended period of
time to assure that she would remain quiet and not cause any more bad public
relations.

41. LISA McPHERSON, suffering severe dehydration, ultimately died, even
though it was obvious that during the several days prior to her death, she
needed nutrition, liquids and urgent medical care and treatment by licensed
professional medical personnel.

42. The above actions of the Defendants, SCIENTOLOGY, JOHNSON, KARTUZINSKI
and HOUGHTON were carried out by medically untrained and unlicensed personnel of
SCIENTOLOGY pursuant to SCIENTOLOGY'S own internal policies, procedures, and
bulletins.

43. LISA McPHERSON remained in the exclusive care, custody and control of
SCIENTOLOGY from the moment she left the Morton Plant Hospital to the time she
arrived at Columbia/HCA New Port Richey Hospital on December 5, 1995.

44. Prior to deciding to take LISA McPHERSON to a hospital while she
remained in the defendant's exclusive care, custody, and control, the members of
SCIENTOLOGY, willfully, intentionally, methodically, maliciously and as a result
of its members' culpable negligence ignored her medical condition according to
Hubbard's anti-medicine directives and the demand that his and only his methods
were the correct ways of dealing with such mental conditions.

45. On or about December 5, 1995, SCIENTOLOGY, after observing LISA
McPHERSON dead or in a comatose state and severely dehydrated for several days,
apparently decided for the first time to seek or appear to seek professional
medical help and, rather than call 911 for immediate, professional medical help
and an ambulance with medics to take her to the nearest medical facility, Morton
Plant Hospital, they put her in a private van and drove her to a hospital some
24 miles away where the emergency room physician, a fellow Scientologist, DAVID
MINKOFF, M.D., had pre-arranged to meet them in an attempt to conceal her
physical condition and cause of death.

46. The above actions of SCIENTOLOGY from the time of her accident until her
death, lasted a total of 17 days which resulted in the pronounced death of LISA
McPHERSON on December 5, 1995, at Columbia/HCA New Port Richey Hospital due to
extreme bed rest and extreme dehydration.

47. The above actions of SCIENTOLOGY were the result of persisting in their
attempt to subdue the will of LISA McPHERSON, who expressed her desire to leave
SCIENTOLOGY and who had violated the strict rules of SCIENTOLOGY by seeking
outside help, so that she would succumb to the will of SCIENTOLOGY.

48. The above actions of SCIENTOLOGY were the result of their premeditated
design to follow their techniques, bulletins, and procedures, which were
performed by or at the direction of SCIENTOLOGY willfully, intentionally,
maliciously and in total disregard of the rights of LISA McPHERSON in addition
to their culpable negligence and gross negligence in failing to obtain timely
appropriate emergency medical care through licensed medical providers when the
need to do so was overwhelmingly obvious.

49. As a result of the above actions of SCIENTOLOGY, and the Defendants,
LISA McPHERSON suffered extreme physical and mental suffering and pain, anguish
and physical injury while enduring her "ethics handling" and later
inside the Ft. Harrison Hotel from November 18, 1995 to December 5, 1995 in
addition to loss of earnings and net accumulations.

50. As a result of the above actions of SCIENTOLOGY and the Defendants the
sole surviving heir of LISA McPHERSON, her mother, FANNIE McPHERSON, suffered
physically and extreme emotional mental pain and suffering.

COUNT I - STATUTORY WRONGFUL DEATH

51. This is an action for damages for wrongful death pursuant to Florida
Statutes, ?768.16, et seq., known as "Florida Wrongful Death Act."

52. Plaintiff realleges and incorporates the allegations contained in ?1
through ?50 above.

53. The Defendant, DAVID MINKOFF, M.D. participated in this activity with
SCIENTOLOGY by first agreeing and then implementing the following:

(a) without knowledge of her physical condition and without monitoring her
physical condition, writing prescriptions to be administered to LISA McPHERSON
and concealing the fact that these prescriptions would be given to her by
unlicensed personnel and writing them in the names of persons other than LISA
McPHERSON, to facilitate her "Isolation" at the Ft. Harrison Hotel. At
the time the prescriptions were written, MINKOFF and SCIENTOLOGY both knew that
it was illegal to write prescriptions to non-patients of DAVID MINKOFF;

(b) by DAVID MINKOFF agreeing with SCIENTOLOGY to see LISA McPHERSON and
instructing fellow Scientologists in possession of LISA McPHERSON to bring her
body to a distant hospital so as to conceal the true facts associated with her
care and death as well as the cause of death.

54. As a result of the above actions by Defendants, the ESTATE OF LISA
McPHERSON in addition to the aforementioned damages has suffered medical and
funeral expenses.

WHEREFORE, the Plaintiff, ESTATE OF LISA McPHERSON, by and through DELL
LIEBREICH, its Personal Representative, demands judgment against the Defendant,
CHURCH OF SCIENTOLOGY FLAG SERVICE ORGANIZATION, INC.;BENNETTA SLAUGHTER;
PRODEX, INC. d/b/a/ AMC PUBLISHING COMPANY; JANIS JOHNSON M.D.; ALAIN
KARTUZINSKI; DAVID HOUGHTON, D.D.S.; and DAVID MINKOFF, M.D., jointly and
severally, for compensatory damages and punitive damages, together with costs
and other relief as the court may deem just in the premises and demands trial by
jury.

COUNT II - COMMON LAW WRONGFUL DEATH

55. This is a cause of action for common law wrongful death and brought
pursuant to F.S. Sec. 46.021.

57. The Defendant, DAVID MINKOFF, M.D. participated in this activity with
SCIENTOLOGY by first agreeing and then implementing the following:

(a) without knowledge of her physical condition and without monitoring her
physical condition, writing prescriptions to be administered to LISA McPHERSON
and concealing the fact that these prescriptions would be given to her by
unlicensed personnel and writing them in the names of persons other than LISA
McPHERSON, to facilitate her "Isolation" at the Ft. Harrison Hotel. At
the time the prescriptions were written, MINKOFF and SCIENTOLOGY both knew that
it was illegal to write prescriptions to non-patients of DAVID MINKOFF;

(b) by DAVID MINKOFF agreeing with SCIENTOLOGY to see LISA McPHERSON and
instructing fellow Scientologists in possession of LISA McPHERSON to bring her
body to a distant hospital so as to conceal the true facts associated with her
care and death as well as the cause of death.

59. As a result of the above actions by the Defendants, the ESTATE OF LISA
McPHERSON has suffered medical and funeral expenses.

WHEREFORE, the Plaintiff, ESTATE OF LISA McPHERSON, by and through DELL
LIEBREICH, its Personal Representative, demands judgment against the Defendant,
CHURCH OF SCIENTOLOGY FLAG SERVICE ORGANIZATION, INC.;BENNETTA SLAUGHTER;
PRODEX, INC. d/b/a/ AMC PUBLISHING COMPANY; JANIS JOHNSON M.D.; ALAIN
KARTUZINSKI; DAVID HOUGHTON, D.D.S.; and DAVID MINKOFF, M.D., jointly and
severally, for common law compensatory damages and punitive damages, together
with costs and other relief as the court may deem just in the premises and
demands trial by jury.

COUNT III - INTENTIONAL AND RECKLESS INFLICTION OF EMOTIONAL DISTRESS

60. This is an action for damages, including punitive and compensatory,
pursuant to Florida Statute, ?46.021.

61. Plaintiff realleges and incorporates the allegations contained in ?1
through ?50 above.

63. The Defendant, DAVID MINKOFF, M.D. participated in this outrageous
conduct with SCIENTOLOGY by first agreeing and then implementing the following:

(a) without knowledge of her physical condition and without monitoring her
physical condition, writing prescriptions to be administered to LISA McPHERSON
and concealing the fact that these prescriptions would be given to her by
unlicensed personnel and writing them in the names of persons other than LISA
McPHERSON, to facilitate her "Isolation" at the Ft. Harrison Hotel. At
the time the prescriptions were written, MINKOFF and SCIENTOLOGY both knew that
it was illegal to write prescriptions to non-patients of DAVID MINKOFF;

(b) by DAVID MINKOFF agreeing with SCIENTOLOGY to see LISA McPHERSON and
instructing fellow Scientologists in possession of LISA McPHERSON to bring her
body to a distant hospital so as to conceal the true facts associated with her
care and death as well as the cause of death.

64. While imprisoned inside the Ft. Harrison Hotel, LISA McPHERSON demanded
to be set free, banged on the walls and was at times physically restrained or
physically detained by SCIENTOLOGY.

65. The above actions of Defendants, SCIENTOLOGY, KARTUZINSKI, JOHNSON,
HOUGHTON and MINKOFF are outrageous in that they are utterly intolerable in a
civilized community.

WHEREFORE, the Plaintiff, ESTATE OF LISA McPHERSON, by and through DELL
LIEBREICH, its Personal Representative, demands judgment against the Defendant,
CHURCH OF SCIENTOLOGY FLAG SERVICE ORGANIZATION, INC.; JANIS JOHNSON M.D.; ALAIN
KARTUZINSKI; DAVID HOUGHTON, D.D.S.; and DAVID MINKOFF, M.D., jointly and
severally, for common law compensatory damages and punitive damages, together
with costs and other relief as the court may deem just in the premises and
demands trial by jury.

COUNT IV - FALSE IMPRISONMENT

67. This is an action for damages, including punitive and compensatory,
pursuant to Florida Statute, ?46.021.

68. Plaintiff realleges and incorporates the allegations contained in ?1
through ?50 above.

70. The Defendant, DAVID MINKOFF, M.D. participated in this activity with
SCIENTOLOGY by first agreeing and then implementing the following:

(a) without knowledge of her physical condition and without monitoring her
physical condition, writing prescriptions to be administered to LISA McPHERSON
and concealing the fact that these prescriptions would be given to her by
unlicensed personnel and writing them in the names of persons other than LISA
McPHERSON, to facilitate her "Isolation" at the Ft. Harrison Hotel. At
the time the prescriptions were written, MINKOFF and SCIENTOLOGY both knew that
it was illegal to write prescriptions to non-patients of DAVID MINKOFF;

(b) by DAVID MINKOFF agreeing with SCIENTOLOGY to see LISA McPHERSON and
instructing fellow Scientologists in possession of LISA McPHERSON to bring her
body to a distant hospital so as to conceal the true facts associated with her
care and death as well as the cause of death.

71. At all times material herein, Defendants, BENNETTA SLAUGHTER and AMC
PUBLISHING COMPANY, with knowledge of LISA McPHERSON'S prior "psychotic
break" from similar programs, intentionally and recklessly subjected LISA
McPHERSON to "ethics" with the very known foreseeable result of
causing her to experience a "psychotic break", which would then
forseeably result in forced "Isolation."

72. Scientology "ethics" did in fact cause LISA McPHERSON to
experience a "psychotic break", which lead her into being forced into "Isolation",
(as these terms are used in Scientology). While imprisoned inside the Ft.
Harrison Hotel, LISA McPHERSON demanded to be set free, banged on the walls and
was at times physically restrained or physically detained by SCIENTOLOGY.

WHEREFORE, the Plaintiff, ESTATE OF LISA McPHERSON, by and through DELL
LIEBREICH, its Personal Representative, demands judgment against the Defendant,
CHURCH OF SCIENTOLOGY FLAG SERVICE ORGANIZATION, INC.;BENNETTA SLAUGHTER;
PRODEX, INC. d/b/a/ AMC PUBLISHING COMPANY; JANIS JOHNSON M.D.; ALAIN
KARTUZINSKI; DAVID HOUGHTON, D.D.S.; and DAVID MINKOFF, M.D., jointly and
severally, for common law compensatory damages and punitive damages, together
with costs.

76. As part of its established practices, Defendant, SCIENTOLOGY, provides
treatment and care in excess of 24 hours to its members who it decides, through
its managing agents, to forcibly keep in isolation. SCIENTOLOGY has many
facilities where it places the members of SCIENTOLOGY in isolation, one of which
is the Ft. Harrison Hotel, which is a "facility" as defined in F.S.
Sec. 400.021(8) and (11); F.S. Sec. 400.402 (3); and F.S. Sec. 400.551(1), which
under Florida Law was required to be licensed and professionally staffed.

77. On November 18, 1995, LISA McPHERSON became a member of the protected
class as defined in Chapter 400, Florida Statutes, and Title 58, Florida
Administrative Code, when, while in the exclusive care, custody and control of
Defendant, FLAG, LISA McPHERSON became incapable of caring for herself, needed
psychological and medical care, and was unable to ambulate.

78. The Defendant, FLAG, had the duty to be licensed with trained personnel
per F.S. Sec. 400.404 and 400.407 to provide that level of care prescribed under
Florida Statutes, Chapter 400, and Title 58 or transfer LISA McPHERSON to an
appropriate licensed medical facility or one defined in Florida Statute,
?400.011, .402, .551 or Title 58, Florida Administrative Code.

79. Rather than transfer LISA McPHERSON, FLAG chose to keep her and thus
assumed the duties under Chapter 400 and Title 58, to wit:

(a) provide supervision of diets as to quantity and quality;

(b) provide daily observation and awareness of health:

(c) promptly note in LISA McPHERSON's records any change in her normal
appearance or state of health or well-being;

(d) notify LISA McPHERSON's family when she exhibited a significant change;

(e) protect and facilitate the exercise of LISA McPHERSON's rights and
freedoms in accordance with the Resident Bill of Rights per Florida Statute,
?410.428;

82. The above actions of the Defendant, FLAG, violated the Bill of Rights of
LISA McPHERSON as established in Florida Statutes, ?400.428, for which the
Plaintiff seeks damages including punitive damages as provided in Florida
Statutes, ?400.429, plus costs and attorney fees as provided therein.

WHEREFORE, the Plaintiff, ESTATE OF LISA McPHERSON, by and through, DELL
LIEBREICH, its Personal Representative, demands judgment against the Defendant,
CHURCH OF SCIENTOLOGY FLAG SERVICE ORGANIZATION, INC., for compensatory damages,
punitive damages, and attorney fees together with costs and other relief as the
court may deem just in the premises and demands trial by jury.

84. At all times material times herein LISA McPHERSON was a "disabled
adult" as that term is defined in F.S. 415.102(10) and a "victim"
as defined in F.S. 415.102(35) in Chapter 415 of Florida Statutes entitled "Protection
From Abuse, Neglect, and Exploitation."

85. At all times material herein FLAG and its staff were "care givers"
as that term is defined in F.S. Sec. 415.102 (4), but lacked "specified
medical personnel" as defined in F.S. Sec. 415.201(33).

86. FLAG, by virtue of its authoritarian position to and its forced
isolation and imprisonment of LISA McPHERSON, had a "fiduciary relationship"
to LISA McPHERSON as that term is defined in F.S. Sec. 415.102(15) and held a "position
of trust" to her as defined in F.S.Sec.415.102(24).

87. The above actions of FLAG inflicted severe "psychological injury"
as that term is defined in F.S. Sec. 415.201(30).

88. The above stated actions by FLAG were acts of "neglect" toward
LISA McPHERSON as defined in F.S. 415.102(20), while she lacked the "capacity
to consent" as that term is defined in F.S. 415.102(19).

90. As a result of the above statutory violations the estate is entitled to
punitive damages, compensatory damages, costs, and attorney fees per Chapter
415.

WHEREFORE, the Plaintiff, ESTATE OF LISA McPHERSON, by and through DELL
LIEBREICH, its Personal Representative, demands compensatory and punitive
damages against the Defendant, CHURCH OF SCIENTOLOGY FLAG SERVICE ORGANIZATION,
INC., together with costs, attorney fees and other relief as the court may deem
just in the premises and demands trial by jury.

COUNT VII - FRAUD

91. Plaintiff realleges and incorporates herein the allegations in ?1
through ?50 above.

92. At all times material herein, FLAG misrepresented to LISA McPHERSON that
it promulgated techniques and practices that were scientifically proven and
would ultimately end in LISA McPHERSON's acquiring a god-like and disease free
existence. These claims were started in 1950 when Hubbard claimed that his
methods could deliver health, memory and happiness. It continued into
SCIENTOLOGY with further promises of states "far beyond human" and a
state of "homo novis" and "operating thetan" where one can
operate without a body. These claims have been made in numerous SCIENTOLOGY
publications and promotional pieces intended to have the person pay for books,
classes, courses and other SCIENTOLOGY procedures.

93. At the time these misrepresentations were made, SCIENTOLOGY knew them to
be false and intended LISA McPHERSON to rely upon them to her detriment by
paying into SCIENTOLOGY hundreds of thousands of dollars without obtaining the
guaranteed results.

94. LISA McPHERSON relied upon these misrepresentations to her detriment,
which culminated in her loss of payments, forced psychological breakdown, total
isolation, severe dehydration and death.

WHEREFORE, Plaintiff, ESTATE OF LISA McPHERSON, by and through DELL
LIEBREICH, its Personal Representative, demands a refund of all sums paid to
CHURCH OF SCIENTOLOGY, plus compensatory and punitive damages, against the
Defendant, CHURCH OF SCIENTOLOGY FLAG SERVICE ORGANIZATION, INC., together with
costs and other relief deemed just by the court and demands trial by jury.

COUNT VIII - RESCISSION OF CONTRACT

95. Plaintiff realleges and incorporates herein the allegations in ?1
through ?52 above.

96. In exchange for money paid, FLAG contracted with LISA McPHERSON under an
unconditional guarantee to provide her with programs and techniques which would
benefit her physically and mentally.

97. LISA McPHERSON did not receive any benefit of the bargain for which she
contracted, but FLAG received substantial sums of money from LISA McPHERSON.

98. Plaintiff seeks rescission of contract and a refund of all monies paid
to FLAG and all other Scientology entities as a result of the failure of
SCIENTOLOGY to provide any guaranteed benefits.

WHEREFORE, Plaintiff, DELL LIEBREICH, as Personal Representative of the
ESTATE OF LISA McPHERSON, demands compensatory damages against the Defendants,
CHURCH OF SCIENTOLOGY FLAG SERVICE ORGANIZATION, INC. together with costs and
other relief deemed just by the court and demands trial by jury.

COUNT IX - DECEPTIVE TRADE PRACTICES

99. Plaintiff realleges paragraphs 1 through 50 above.

100. This is an action brought under F.S. Sec. 501.204 known as Deceptive
and Unfair Trade Practices for damages in excess of $15,000.

101. At all times material herein, LISA McPHERSON was a "consumer"
as defined under Chapter 501, Florida Statutes.

102. At all times material herein, FLAG was a "business" engaged
in trade or commerce as defined under Chapter 501, Florida Statutes.

103. Defendant misrepresented to LISA McPHERSON for 18 years, while she was
a member of Defendant, that Defendant had created and maintained a
scientifically proven set of programs and philosophy that would result in all
those who paid and received these certain programs a new state of being and
achieving a god-like state of being, free of disease, insanity, mental disorders
or disease, and physical illnesses.

104. At the time Defendant made these representations to seduce LISA
MCPHERSON into joining the Defendant and continuously thereafter for 18 years,
the Defendant knew that these representations were unproven and unsound as to
the claimed ultimate goal, yet received substantial funds from LISA MCPHERSON
for her continued "growth" within the many levels of programs,
including the achievement by LISA McPHERSON of obtaining "clear."
105. Rather than provide a loving church family and the means to a god-like
status, free of mental and physical disease as represented by the Defendant
through its many publications, videos, and courses purchased by LISA MCPHERSON,
the Defendant caused LISA MCPHERSON to experience a psychotic breakdown and in
need of urgent psychological and medical care, which Defendant refused to
provide even after it became obvious that the physical and mental abuse
Defendant subjected her to was rapidly leading to her premature death.

106. The above actions of Defendant are "unconscionable acts or
practices, and unfair or deceptive acts or practices in the conduct of
Defendant's trade or commerce" and therefore unlawful per F.S. Sec.
501.204, thus entitling the Plaintiff to compensatory damages, punitive damages,
costs, and attorney fees per Chapter 501, Florida Statutes.

WHEREFORE, Plaintiff, ESTATE OF LISA MCPHERSON, by and through DELL
LIEBREICH, its Personal Representative, demands compensatory damages, punitive
damages, and attorney fees against the Defendant, CHURCH OF SCIENTOLOGY FLAG
SERVICE ORGANIZATION, INC., together with costs and other relief deemed just by
the court and demands trial by jury.

COUNT X - INTENTIONAL/RECKLESS INFLICTION OF EMOTIONAL DISTRESS

107. Plaintiff realleges paragraphs one through 50 above.

108. At all times material herein, Defendants, BENNETTA SLAUGHTER and PRODEX
INC. d/b/a/ AMC PUBLISHING COMPANY, intentionally and recklessly subjected LISA
McPHERSON to Scientology "ethics" with the very known foreseeable
result of causing her to experience a "psychotic break".

109. Scientology "ethics" did in fact cause Lisa to experience a "psychotic
break", which lead her into being forced into "Isolation", (as
these terms are used in Scientology), all of which caused LISA McPHERSON to
experience extreme mental suffering and emotional damage. WHEREFORE, Plaintiff,
the ESTATE OF LISA MCPHERSON, by and through DELL LIEBREICH, as Personal
Representative, demands compensatory damages and punitive damages against
Defendants, BENNETTA SLAUGHTER and PRODEX, INC. d/b/a AMC PUBLISHING COMPANY,
jointly and severally, together with costs and other relief deemed just by the
court and demands trial by jury.

COUNT XI - BATTERY

110. Plaintiff realleges paragraphs 1 through 50 above.

111. During her confinement at the Ft. Harrison Hotel, LISA McPHERSON was
subjected to repeated battery upon her person without her consent by FLAG, which
consisted of repeated non-consensual physical contact as well as repeated forced
feedings and forced injections or other delivery of medications and other
substances.

WHEREFORE, Plaintiff, the ESTATE OF LISA MCPHERSON, by and through DELL
LIEBREICH, as Personal Representative, and demands compensatory damages,
punitive damages against CHURCH OF SCIENTOLOGY FLAG SERVICE ORGANIZATION, INC.,
together with costs and other relief deemed just by the court and demands trial
by jury.

114. At all times material herein, FLAG, as owner of the premises and the
organization which housed LISA McPHERSON had the duty to LISA McPHERSON to take
reasonable action to give her first aid after it knew she was ill or injured and
to care for her by summoning appropriate emergency medical professionals or
providing her appropriate medical care until it knew she could be cared for by
licensed medical professionals.

115. FLAG breached its duty to LISA McPHERSON by taking no action to seek
and provide her urgent medical care she obviously needed.

116. The above actions by FLAG was the result of its reckless, intentional
and culpable negligence at a time when LISA McPHERSON was physically and
mentally unable to care for herself.

WHEREFORE, Plaintiff, ESTATE OF LISA MCPHERSON, by and through DELL
LIEBREICH, its Personal Representative, demands compensatory damages, and
punitive damages against the Defendant, CHURCH OF SCIENTOLOGY FLAG SERVICE
ORGANIZATION, INC., together with costs and other relief deemed just by the
court and demands trial by jury.

119. Defendants, FLAG, MINKOFF, JANIS JOHNSON, DAVID HOUGHTON and ALAIN
KARTUZINSKI conspired to keep LISA McPHERSON in isolation inside the Ft.
Harrison Hotel against her will until she conformed to the rule of Scientology
from November 18, 1995 to December 5, 1995.

120. On December 5, 1995, it became apparent to these Defendants that LISA
McPHERSON was near death and in need of urgent medical care. Rather than call
911 or transport her to the closest emergency room at Morton Plant Hospital,
these Defendants decided to transport her forty-five minutes away to the
Columbia/HCA New Port Richey Hospital where MINKOFF was waiting in order to
conceal her physical condition and death.

121. As a result of this conspiracy, LISA McPHERSON suffered extreme mental
and physical pain and suffering.

WHEREFORE, Plaintiff, ESTATE OF LISA MCPHERSON, by and through DELL
LIEBREICH, its Personal Representative, demands compensatory damages, and
punitive damages against the Defendants, CHURCH OF SCIENTOLOGY d/b/a CHURCH OF
SCIENTOLOGY FLAG SERVICE ORGANIZATION, INC.; DAVID MINKOFF; JANIS JOHNSON; ALAN
KARTUZINSKI; and DAVID HOUGHTON together with costs and other relief deemed just
by the court and demands trial by jury.

COUNTY XIV - VIOLATION OF CHAPTER 458- PRACTICING MEDICINE WITHOUT A LICENSE

122. Plaintiff realleges Paragraphs 1 through 50 above.

123. The Defendant, FLAG, by and through Defendants, ALAIN KARTUZINSKI,
JANIS JOHNSON, DAVID HOUGHTON with the help of Defendant, DAVID MINKOFF in
illegally obtaining prescription drugs for them to administer to LISA McPHERSON,
practiced medicine upon LISA McPHERSON without a license as required by Chapter
458 of the Florida Statutes by administering orally and via muscular injections
prescription drugs which were illegally obtained at the time the Defendants
KARTUZINSKI, JOHNSON, AND HOUGHTON were unlicensed in the State of Florida.

124. The above actions of the Defendants in combination with the Defendants
administering vitamin and mineral concoctions resulted in LISA McPHERSON'S
dramatic weight loss, severe dehydration and the inability to ambulate with the
further result of continuing physical and mental pain, suffering, and
imprisonment.

WHEREFORE, Plaintiff, ESTATE OF LISA MCPHERSON, by and through DELL
LIEBREICH, its Personal Representative, demands compensatory damages and
punitive damages against the Defendants, CHURCH OF SCIENTOLOGY FLAG SERVICE
ORGANIZATION, INC.; DAVID MINKOFF; JANIS JOHNSON; ALAN KARTUZINSKI; and DAVID
HOUGHTON together with costs and other relief deemed just by the court and
demands trial by jury.

I HEREBY CERTIFY that a true and correct copy of the foregoing has been
furnished by U.S. Mail this ____ day of November, 1997, to MORRIS WEINBERG, JR.,
ESQ. and LAURA L. VAUGHAN, ESQ., 401 East Jackson Street, Suite 2525, Tampa,
Florida 33602.